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Conflicts of Interest Code of Conduct

The same product supplier gives a representative a gift worth R800 in December 2025 and another worth R700 in January 2026. He receives nothing else from that supplier. Do these gifts fall within the definition of an immaterial financial interest?

RE5 practice question with a worked answer. This is one of hundreds of FSCA RE5 questions in the RegulatoryExams question bank.

  1. a) Yes. The R1 000 limit is tested per calendar year, and neither year's total exceeds it.Correct
  2. b) No. The two gifts total R1 500 within a period of twelve months, which exceeds the limit.
  3. c) No. A representative may accept only one gift from the same supplier in any twelve months.
  4. d) Yes. Each gift is tested on its own, so any number of gifts under R1 000 is acceptable.

Why this is the answer

An immaterial financial interest may not exceed R1 000 in aggregate in any calendar year from the same third party. December 2025 and January 2026 fall in different calendar years, so the totals are R800 and R700. It is not a rolling twelve-month test, there is no limit on the number of gifts, and gifts within the same calendar year are added together.

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